OleeVia Grameen Credits Private Limited (hereinafter referred to as “OGCL” or the “Company”) is a state-of-the-art new age Non-Banking Finance Company with the most modern and innovative Products & Services offered to their customers. The prime objective of OGCL is to support the tribes in promoting their traditional farming methodologies by supporting them with micro-lending for affordable rates. The Company aims to provide easy and affordable credit lines to Tribals, Farmers, and Small & Medium Business classes to be self-sufficient in their activities. OGCL is led by experienced banking professionals. The collective experience of the top management is 100+ years. The Company has a vision of becoming a well-reputed value-centered commercial bank in the next 8 to 10 years.

In pursuance of the Companies Act, 2013, and the regulations prescribed by the Reserve Bank of India, OGCL hereby formulates and adopts these Securities Trading Rules (hereinafter referred to as the “Rules”) for the purpose of ensuring compliance with the provisions of the Companies Act, 2013 and the RBI regulations governing securities trading.

• “Act” shall mean the Companies Act, 2013 and the rules made thereunder.
• “Board” shall mean the Board of Directors of OGCL.
• “Insider” shall mean a person who is or was a connected person or deemed to be a connected person with OGCL and who is reasonably expected to have access to unpublished price-sensitive information in relation to the securities of the Company, or who has received or has had access to such information.
• “RBI” shall mean the Reserve Bank of India.
• “Securities” shall mean equity shares, preference shares, debentures, bonds, and any other financial instruments issued by OGCL from time to time.
• “Trading Window” shall mean the period during which trading in the securities of the Company is permitted.

• No insider shall trade in the securities of OGCL when in possession of unpublished price-sensitive information.
• The Trading Window shall remain closed for insiders from the end of the quarter until 48 hours after the announcement of the financial results for the quarter.
• The Trading Window shall remain closed for insiders from the date of the Board Meeting for considering any corporate action, including declaration of dividend or issue of securities, until 48 hours after the said information is made public.
• The Trading Window shall remain closed for insiders during the period when the Company is in possession of unpublished price-sensitive information.
• No insider shall communicate or provide any unpublished price-sensitive information to any person, except where such communication is made in the ordinary course of business or profession.

• Any person, including an insider, who intends to trade in the securities of OGCL during the Trading Window, shall obtain prior clearance from the Compliance Officer of OGCL.
• The Compliance Officer shall maintain a record of all requests received for trading in the securities of OGCL during the Trading Window, including the reasons for such trades.
• The Compliance Officer shall be responsible for monitoring compliance with these Rules.

• OGCL should ensure that all material information related to its business, financials, and securities is disclosed in a timely and accurate manner to the regulatory authorities and investors.
• This includes the filing of periodic reports such as quarterly and annual financial statements, disclosure of any material events or information that could impact the company's operations or securities and complying with insider trading regulations.

• These Rules may be amended by the Board from time to time, subject to the provisions of the Companies Act, 2013 and the RBI regulations governing securities trading.

These Rules shall come into effect from the date of their adoption by the Board of OGCL.

• Any insider who trades in the securities of OGCL during the prohibited period or in violation of these Rules shall be liable for penalties and disciplinary action, which may include termination of employment or other actions as deemed appropriate by the Board.
• Any person who violates these Rules shall be liable for penalties and disciplinary action, which may include cancellation of trades and other actions as deemed appropriate by the Board.